MOTION FOR NEW TRIAL NOW COMES Defendant (or plaintiff) by his undersigned attorney to this Honorable Court

and respectfully moves that the decision of this Honorable Court dated March 1, 1987 and received on March 7, 1988 be set aside and new trial be granted on the following grounds: (here give the grounds provided for in Rule 37, Rules of Court; such as fraud, accident, mistake, or newly discovered evidence or excessive damages awarded) ARGUMENTS (here se forth the reasons in support of the ground/s mentioned) WHEREFORE, it is respectfully prayed that the decision of this Honorable Court be set aside and new trial be granted. (With Notice of Hearing, Proof of Service and Explanation)

MOTION TO WITHDRAW WITH SUBSTITUTION OF COUNSEL COMES NOW, JRC, Counsel on record for the defendant and to this Honorable Court respectfully moves to withdraw as counsel of said defendant with the express consent of said defendant as shown in this motion; That in the substitution thereof, Atty. BFG whose services have been engaged by defendant hereby enters his appearance as counsel for defendant; That upon approval of this Honorable Court, all pleadings, notices, and papers in connection with this case be addressed to new counsel BFG with address at No. 7 Sta. Catalina, Sampaloc, Manila. With my consent: ___________________________ BFG New counsel ________________________ Address P.T.R. Issue______ No.______ Date & Place of

IBP O.R. No._____ Date & Place of Issue_____

(copy furnished: adverse counsel) (Proof of Service and Explanation)

MOTION FOR POSTPONEMENT OF HEARING COMES NOW Defendant through undersigned counsel unto this Honorable Court respectfully states: That the above entitled case is set for hearing on July 7, 1988; That counsel for defendant is afflicted with influenza and is now under the medical care of Dr. PTB. A copy of the physicians certificate under is hereto attached. WHEREFORE, it is respectfully prayed that the hearing set on July 7, 1988 be reset to another day preferably on the first week of August 1988 or at the convenience of this Honorable Court. Manila, Philippines, July 2, 1988.

Sgd. ALC Counsel for defendant (Notice of Hearing) (Proof of Service and Explanation)

MOTION FOR JUDGMENT ON THE PLEADINGS COMES NOW, the Plaintiff through the undersigned counsel and to this Honorable Court respectfully alleged: 1. That in the answer of defendant filed on July 1, 1988 be admitted having signed the promissory note and merely interposed defense that he was asking for time within which to pay the obligation.

2.

That said answer does not tender any issue and in fact it can be read therefrom that defendant admitted his obligation.

WHEREFORE, it is respectfully prayed that this Honorable Court render judgement on the pleadings. Manila, Philippines, July 5, 1988. XYZ Counsel for Plaintiff (With Notice of Hearing, Proof of Service and Explanation)

MOTION FOR EXECUTION OF JUDGMENT COMES NOW, the Plaintiff through undersigned counsel and to this Honorable Court respectfully alleged: 1. 2. 3. 4. That judgment was rendered by this Honorable Court in favor of the plaintiff on June 1, 1988. That said judgment was duly received by the defendant on June 5, 1988 as shown in the registry return card; That up to the present, the defendant had not filed any motion for reconsideration or had appealed from said decision, hence the decision has become final and executory.

WHEREFORE, it is respectfully prayed that an order be issued by this Honorable Court for a writ of execution of said judgment.

Manila, Philippines. July 5, 1988. XYZ Counsel for Plaintiff (With Notice of Hearing, Proof of Service and Explanation)

NOTICE OF HEARING IN EX-PARTE AND NON-LITIGOUS MOTION

The Branch Clerk of court RegionalTrial Court

National Capital Judicial Region Branch______, Makati, Metro Manila GREETINGS: Considering the urgency and non-litigious nature of the above motion, please submit the same forthwith upon receipt for the consideration and approval of the Honorable Court.